Case No. IA-2016-329987-1

Date issued: Nov. 16 2017

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TURBOFAC Commentary (218 words)

Notes:

1) This guidance letter was issued in response to a license request made prior to the issuance of the first iteration of Iran GL J, and the letter was issued after the issuance of both Iran GL J and Iran GL J-1) . The letter is, therefore, generally overtaken by events, but it does contain one notable interpretive statement. OFAC says:

"To the extent that the proposed activities involve U.S. persons including U.S. person owners or lessors of Air Astana aircraft, or are otherwise outside the scope of GL J-1, it would be inconsistent with current licensing policy to issue a specific license authorizing such activities."

With respect to the bolded portion of the sentence, OFAC appears to suggest, in a way that is consistent with other statements of the agency, that the...